Walker v. Health Benefit Management Cost Containment, Inc.
Plaintiffs Thurman and Barbara Walker filed a motion to remand their workers' compensation bad-faith claim against Service Lloyds Insurance Company and Health Benefit Management Cost Containment, Inc. (HBM), which had been removed to federal court by Service Lloyds. Defendants argued for ERISA preemption and against the application of 28 U.S.C. § 1445(c), which generally prohibits removal of state workers' compensation cases. The court, presided over by Judge Means, granted the plaintiffs' motion to remand, concluding that ERISA's workers' compensation exemption applied. Furthermore, the court determined that § 1445(c) prohibited removal of bad-faith claims arising under state workers' compensation laws, deeming it an almost laughable anomaly to separate these claims. Consequently, the defendant's motion to stay was denied, as the court divested itself of jurisdiction.